In Californians for Pesticide Reform v. Department of Pesticide Regulation (2010) 184 Cal.App.4th 887, a state statute required the state Department of Pesticide Regulation to assess the risk of harm presented by pesticides used in the state, determine whether they are toxic air contaminants, and adopt measures to control them. The Department established a policy to prioritize pesticides in the order it would review them. (Pesticide Reform, supra, 184 Cal.App.4th at pp. 893-894.) The Court concluded the prioritization policy was exempt from the APA as an internal management policy because it required no affirmative conduct by an affected party. (184 Cal.App.4th at pp. 907-908.) However, we emphasized that the "Department was authorized to evaluate all pesticides in California, and the director was given the discretion to determine the order in which the pesticides would be evaluated. ... The prioritization policy will not determine if the pesticides will undergo review, but merely prioritize when the pesticides will undergo review." (Id. at p. 909.)